Navistar International Corporation

Based on public information, there is evidence that the company has published a statement from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. The statement is contained within the Code of Conduct and it discusses ethical behaviour. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement that specifically supports the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is no readily available evidence that the company has published a statement of values representing high standards of business conduct. TI notes that the company highlights integrity as a behaviour to be followed by employees, but there is limited explanation of what is meant by this and what it means for the company.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee’s responsibilities include reviewing the company’s compliance with the Code of Conduct and any matters raised by the Corporate Compliance Officer.

Based on public information, there is evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. Steven Covey, General Counsel, holds the position of Chief Ethics Officer.

Based on public information, there is evidence that the Audit Committee reviews the Board’s and the company’s compliance with the Code of Conduct, and any waivers that are approved. The company therefore scores 1. To score higher the company would need to provide evidence of a major, heavyweight, periodic review, of the entire ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence of a formal, written plan that guides Board or senior management review, or evidence of the implementation of improvement plans.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is some evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. It appears to be conducted through the Enterprise Risk Management process. However, there is no readily available evidence of mitigation plans, their ownership or implementation timescales. The company therefore scores 1. To score higher the company would need to provide further evidence that anti-corruption specifically forms part of the company’s risk assessment procedure, and that this procedure is clearly implemented enterprise-wide.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. TI notes that the company expects representatives to abide by national laws and to not offer bribes to government officials. However, there is no evidence of formal procedures or contractual rights to ensure that these standards are met.

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption, including improper gifts and payments. The company therefore scores 1. To score higher the company would need to provide evidence that it prohibits kickback.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero-tolerance.

Based on public information, there is evidence that the company’s Code of Conduct is easily accessible to Board members, employees and third parties. The Code is available online in English, but evidence suggests that the company operates in numerous locations worldwide. The company therefore scores 1.

Based on public information, there is evidence that the Code of Conduct is easily understandable and clear to Board members, employees and third parties. It is written in comprehensible language and does not contain dense, legal terms.

Based on public information, there is evidence that the Code of Conduct applies to all employees and Board members.

Based on public information, there is evidence that the company has a clear policy on conflicts of interest that applies to all employees and Board members. It contains a definition of a conflict of interest and several examples.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. It prohibits cash gifts and sets upper limits for gift exchange.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, the policy does not set clear upper limits or a specific threshold necessary for senior authorisation. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy that prohibits facilitation payments. However, the company provides no guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is evidence that the company regulates political contributions to prevent corruption or other undue influence. Employees may not use any company facilities, supplies, equipment or funds for any political activities. The company therefore scores 1. To score higher the company would need to provide further evidence of the mechanisms to regulate political contributions and publically disclose all political contributions.

Based on public information, there is evidence that the company has a policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. Employees must contact the Law Department to determine whether contact with government personnel may constitute as lobbying. However, guidelines on its applications are not clear and there is no evidence that the company discloses the issues on which it lobbies. The company therefore scores 1.

Based on public information, there is evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. All contributions must be approved by the Director, Corporate Communications and Community Affairs. However, the company does not appear to publically disclose the recipients of such contributions. The company therefore scores 1.

Based on public information, there is insufficient evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. TI understands that the company has Corporate Policies to supplement the Code of Conduct. However, these policies are not publicly available.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible and secure, for employees to report concerns or instances of suspected corrupt activity. This includes a compliance hotline operated by an independent company, which allows anonymous reporting.

Based on public information, there is evidence that the company has whistleblowing channels and that across geographies, all employees have access to more than one reporting channel.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. This includes local or corporate Human Resources, the Compliance Department, the Law Department and the Compliance Hotline.

Based on public information, there is evidence that the company has a clear, legally enforceable, non-retaliation policy for bona fide reporting of corruption. However, there is no evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.